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Complying With OSHA's PPE Standard

Karsten Manufacturing Corp., maker of Ping golf balls, clubs and clothing, wasted no time launching a compliance effort when OSHA amended its personal protective equipment standard last July. The Phoenix, Ariz., firm assembled a task force of workers, supervisors, and health and safety staff to assess hazards for the plant's 1,000 plus jobs.

And the corporate EHS department recruited Alexander & Alexander loss control consultant JoAnn Sullivan to help. Complying with the updated standard enabled Karsten to revisit its job safety analysis process, boost its safety culture, and probably prevent some injuries, Sullivan says. She calls the new hazard assessment requirement of the PPE standard a 'terrific tool for empowering employees to understand hazards and work safer.'

Open to interpretation

To safety managers at smaller manufacturing firms, especially those without job safety analyses in place already, the new requirement is anything but 'terrific.' Instead, professionals who talked to Industrial Safety and Hygiene News used words like vague, confusing, and ambiguous to describe the regulation.

The hazard assessment section is the most frequently cited part of the standard. OSHA delayed enforcement of the hazard assessment as well as the training requirements of the rule 90 days after it went into effect July 5, 1994, in response to employers who contended they needed more time to conduct workplace surveys. But even now, many safety pros say they are not sure they are doing the right thing.

This article attempts to demystify the amendment to the PPE standard, and give safety managers tips for assessing hazards.

The common complaint of safety pros at small manufacturing facilities is that OSHA's instruction to document workplace hazard assessments (.132 d) is unclear. The standard simply tells employers to 'verify that the required workplace hazard assessment has been performed through a written certification.'

Bill Schuchman of the Metropolitan manufacturers' Association fields calls from employers who want to know what a written certification entails. Just how detailed do they have to get on paper? Schuchman offers his own interpretation of the rule. Trouble is, he says, what OSHA expects is anybody's guess. Two people could interpret the requirements very differently and arbitrarily, he says.

Small employers and safety pros might prefer a cookie cutter method for performing a hazard assessment. But assessments need to be customized per the workplace, so there is no universal set of instructions to follow.

Different companies' compliance efforts are testimony to the confusion. At one extreme are firms like Karsten that go to the extent of updating their job safety analysis records. Joanne Sullivan explains: 'If you're going to do a physical hazard assessment, some hazards don't require PPE; we're looking at injuries associated with equipment as well as lifting and materials handling- we decided we couldn't go in and do a half job.'

Meanwhile, a safety manager at a Texas oil company wonders if his facility's safety manual will suffice as a hazard assessment. 'That's the way we interpreted it. But we're not sure,' he says.

And at a small New Jersey chemical manufacturer, the supervisor who says he was 'stuck with safety responsibility' doesn't plan to do anything different. 'Isn't hazard analysis just good housekeeping?' he asks.

What OSHA wants

(Chart: PPE Standard Citations) Even in the most proactive firms, hazard assessment records vary according to who interpreted the standard, says A.D. Little Senior Consultant Matthew Allen. Allen says he visits facilities that have one page hazard assessments and others that have very detailed documentation. 'I'm not saying they didn't interpret it the way it was written. Both types of firms have high compliance, but interpreted the standard differently,' he says.

To be sure, OSHA inspectors say the biggest problem they see with the PPE standard is not confusion among employers. it's ignorance. 'A lot of employers aren't aware of the hazard assessment requirement,' says Robert Rutt, assistant area director for safety at OSHA's Harrisburg, Pa., office.

And then, OSHA officials say, some employers just make compliance difficult for themselves. 'Employers get a little overwhelmed and think we're looking for a lot more than we are,' Salerno says.

'To me it seems rather simple,' says Baton Rouge Assistant Area Director for OSHA Carl Grose. 'It's not a very technical standard.'

Another OSHA investigator in Mobile, Ala. spoke to a group of 300 employers about the standard. 'A lot of folks want to do things by the letter, and a performance-based standard like this throws them off,' he explains.

Indeed, full-blown job safety analyses like Karsten Manufacturing chose to conduct are not necessary for compliance with the PPE standard, OSHA officials say. Safety managers who lack the time and resources to revisit every job with a detailed hazards analysis can still get into compliance. 'Don't make a bigger deal of this than it is,' says Sullivan. 'This is absolutely not rocket science.'

'OSHA's intention was not to force small firms to hire a consultant to spend 100 hours writing hazard assessments,' says A.D. Little's Allen. In fact, one OSHA area director in Wisconsin says, 'In cases where workers are using PPE properly and the only [violation we find is related to] written certification, we don't issue penalties.'

Here are tips OSHA compliance inspectors around the country and several safety consultants offer for conducting and documenting hazard assessments:

OSHA inspectors say they start compliance audits with a review of injury and illness logs. That's a good place for safety managers to start too, they suggest. 'Make sure there aren't any injuries there that could have been prevented by PPE.' workers' comp records can be revealing too. For example, if you note that a lot of workers have had objects irrigated from their eyes, scrutinize your eye protection selection.

Recruit managers and workers to observe job hazards. Sets of eyes from other departments will notice safety hazards regulars might overlook. Involving the employee also introduces a sense of ownership. 'Get employees involved from the beginning and this is a tremendous opportunity to work on establishing a safety culture,' Sullivan says.

Include any records of past industrial hygiene surveys, safety evaluations, or labor-management committee meetings that have identified hazards in your hazard assessment.

Hazard assessments need not be conducted for every employee, but should be job and area based. Do not overlook workers who occasionally enter hazardous areas. For instance, the secretary who walks through the production area to collect time cards once a week is exposed to hazards like full-time workers in that area, points out Matthew Allen.

Small facilities with a lot of job cross-over should consider training all workers in use of all PPE. 'It's probably better to do it now than to wait until they need training,' Allen says.

Then estimate the potential for injuries for each of the basic hazard categories. Determine the level of risk and seriousness of potential injury from each of the hazards found, and consider possible exposure to several hazards simultaneously.

Write down everything. Although opinions on how much detail is necessary in hazard assessment documentation vary, it is difficult to prove you observed hazards that you haven't written down.

When conducting hazard assessments, think about eliminating the need for protective equipment or modifying the process to eliminate the hazard. 'If you just go in and look at what you've got and say 'I need PPE' you'll spend money. If you look at the process you might find ways to save money,' says safety and hygiene consultant Bob Curtis.

Take advantage of free help. Many safety equipment vendors and insurance carriers perform walk-throughs and hazard assessments. But don't rely solely on outsiders. Remember no one knows the workplace like you or your workers do.

Ask your local OSHA office for help. 'Companies won't call OSHA to say 'this is what we've done' because they don't want to bring attention to themselves. But any additional guidance OSHA can give as to what is an adequate hazard assessment is worthwhile,' Allen says. If you fear an inspector will show up at your door, seek advice anonymously over the phone, suggests one OSHA official.

Sullivan says involving workers and managers in compliance efforts has been a key at the golf equipment manufacturer to fostering loyalty and understanding. 'Karsten's work force is becoming well informed and will have a true understanding of the need for safety' as a result of the compliance drive, she says.

Among the articles in the June 2020 issue of ISHN Magazine, we offer a detailed analysis of different types of face masks, discuss long-term solutions for businesses figuring out their COVID-19 response plans, focus on hand protection, and much more.